Case Digest (G.R. No. L-21938-39) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Vicente Uriarte vs. Court of First Instance of Negros Occidental, et al. (G.R. No. L-21938-39, May 29, 1970), petitioner Vicente Uriarte filed on October 3, 1963 an original petition for certiorari against the Courts of First Instance of Negros Occidental (“Negros Court”) and Manila, Branch IV (“Manila Court”), as well as against Juan Uriarte Zamacona and Higinio Uriarte. He sought annulment of (a) the Negros Court’s April 19 and July 11, 1963 orders dismissing Special Proceeding No. 6344 (intestate settlement of the estate of Don Juan Uriarte y Goite) and (b) the Manila Court’s July 1, 1963 order denying his omnibus motion to intervene and dismiss Special Proceeding No. 51396 (probate of the decedent’s alleged will). A preliminary injunction issued on October 24, 1963 enjoined further proceedings in Manila. On April 22, 1964, petitioner filed a supplemental petition for mandamus (G.R. No. L-21939) to compel the Negros Court to approve his record on appeal from its December 7 Case Digest (G.R. No. L-21938-39) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Initiation of Proceedings
- On November 6, 1961, Vicente Uriarte filed Special Proceeding No. 6344 in the CFI of Negros Occidental for the intestate settlement of Don Juan Uriarte y Goite’s estate, claiming to be his sole natural son.
- The Negros Court appointed the Philippine National Bank as special administrator on November 13, 1961, but the Bank did not qualify.
- Oppositions, Parallel Proceedings, and Motions
- On December 19, 1961, Higinio Uriarte opposed SP No. 6344, alleging existence of a will in Spain and questioning petitioner’s interest.
- On August 28, 1962, Juan Uriarte Zamacona:
- Filed SP No. 51396 in the CFI of Manila for probate of an alleged will.
- Moved in Negros SP No. 6344 to dismiss it, attaching the will and petition for probate.
- Petitioner opposed dismissal in Negros, invoking Rule 75’s “first cognizance” rule.
- On April 19, 1963, the Negros Court dismissed SP No. 6344; reconsideration was denied July 27, 1963.
- Petitioner filed notice of appeal; on December 7, 1963, Negros Court disapproved the record on appeal.
- Supreme Court Actions and Supplemental Petition
- October 3, 1963: Petitioner filed G.R. L-21938 for certiorari to annul the Negros orders (April 19, 1963; July 11, 1963) and the Manila order of July 1, 1963, and to enjoin further proceedings in SP No. 51396.
- October 24, 1963: This Court granted a writ of preliminary injunction.
- April 22, 1964: Petitioner filed G.R. L-21939, a supplemental petition for mandamus to compel the Negros Court to approve his record on appeal.
- July 15, 1964: This Court deferred action on the mandamus petition pending resolution of the certiorari case.
- Status of Underlying Actions
- Negros SP No. 6344 had not proceeded beyond the ineffective appointment of a special administrator.
- Manila SP No. 51396 proceeded, and on October 31, 1962, the Manila Court admitted the will to probate, having denied petitioner’s omnibus motion (filed April 15, 1963) to intervene and dismiss.
Issues:
- Jurisdiction and Venue
- Whether the Manila Court erred in entertaining and not dismissing SP No. 51396 despite prior SP No. 6344 in Negros.
- Whether the Negros Court erred in dismissing SP No. 6344 and failing to recognize its exclusive venue under Rule 75, Section 1.
- Appropriate Remedy
- Whether certiorari lies to annul the orders of dismissal and denial of intervention.
- Whether mandamus lies to compel approval of the record on appeal from the Negros Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)